Kolabri

We are proud of the scientific backbone of our interdisciplinary approach to transfer pricing for software engineering. Therefore, we just published our scientific articles and other materials about the data-driven approach underlying our services. You will also find our recent paper on the Microsoft case https://lnkd.in/ezuSVNVa Have a look and explore the content without any restrictions on: https://lnkd.in/ezvAdC3e  

We are happy that our article “The Microsoft Case: Lessons for Post-BEPS Software Development Cost Contribution Arrangements” was published by Tax Notes International. Finding automated transfer pricing solutions for ensuring that collaborative software engineering complies with the arm’s length principle is what drives our professional and scientific interest at Kolabri. The increasingly complex and decentralized value creation in software engineering presents one of the most critical challenges for #tax and #TP professionals. With cases such as the Microsoft providing illustrative evidence of the tax risks at stake. In our article, we take the Microsoft case as a starting point to identify and discuss critical issues such as #substance requirements as well as challenging preconceptions on #value-added attributable to legacy #IP vis-à-vis ongoing #development activities. In addition to scrutinizing selected qualitative arguments pertaining to the Microsoft Case, we outline quantitative approaches to test and validate such arguments. While the Microsoft Case is rather idiosyncratic, we attempt to derive generalized “lessons learned” for MNEs undertaking #decentralized approaches to #collaborative #software #engineering. Knowing that many of the issues are rather novel and emerging, we at @Kolabri are happy to brainstorm with professionals dealing with similar cases (highly appreciated earlier discussions esp. with you Dr. Klaus Dorner, Richard Slimmen, and Philippe Paumier). Lastly, a great thanks to the kind team at Tax Analysts for the smooth editorial process. Please, find the article under: https://lnkd.in/ewWYjcGF